“The Committee is concerned about the chronic shortage of
housing, in particular social housing, for the most
disadvantaged and marginalized individuals and groups...”
Concluding Observations of the UN Committee
on Economic, Social and Cultural Rights, May 2009

The Participation and the Practice of Rights (PPR) organisation provides tools and support to marginalised groups
actively asserting their right to participate in economic and
social decisions which affect their lives. In 2012, the model
developed and used by PPR groups to make change was
cited as best practice by the United Nations Office of the
High Commissioner for Human Rights.

The Equality Can’t Wait (ECW) campaign is led by people
on the waiting list, in hostels and in poor housing from all
over Belfast. Since 2006 ECW, supported by human rights
organisation PPR have monitored human rights abuses
experienced by residents and have pushed for real change
in peoples lives.

A Critique of the Fundamental Review
of Social Housing Allocations
“Meeting housing need is the main priority. New social homes are of course needed, but
the measures proposed in this document would give applicants more choice and help
the waiting list move more effectively.” – Leo O’Reilly, Permanent Secretary, Department
for Communities, p. 7
“Social housing may not always be the most effective way to meet an individual’s housing needs or the most efficient use of resources” – Department for Communities, p. 34

PPR is deeply concerned that the proposals contained in the Fundamental
Review of Social Housing Allocations focus on reducing the appearance
of housing need, rather than resolving the housing crisis through
building social homes and allocating these in line with objective need.
These proposals are merely short term, stopgap measures that restructure
waiting list processes and procedures. The NIHE’s refusal to support the
urgent building of more social housing, as evidenced by the contradictory
statements of policy quoted above, will mean that the waiting list will always be bloated which no artificial shifting or removing of points can realistically fix.
We have examined the Fundamental Review of Social Housing Allocations
and our main points of contention are that the proposals and, ultimately,
the main thrust of the policy itself does the following:
1. Removes points for homelessness
2. Abolishes intimidation points
3. Promotes private rented housing
4. Applies a punitive approach
5. Subverts the principle of objective need
6. Restricts “reasonable” offers

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Key Point #1

REMOVES POINTS
FOR HOMELESSNESS
Rather than “meeting housing need being the main priority”, an aim identified by the Department for Communities (DfC) and the NI Housing Executive (NIHE), proposals such as the removal of interim accommodation
points (Proposal 9) from the selection scheme merely reduce the appearance of need. These proposals do not actually alleviate the root of NI’s
housing crisis which is the shortage of decent accommodation needed to
support Northern Ireland’s growing population.


Every single point matters in terms of social housing allocation. Therefore,
there is no substantive purpose to remove interim accommodation points
awarded to homeless applicants who have been in NIHE-arranged temporary housing for at least six months because data shows that people are
waiting for up to two years before finding permanent accommodation.



Surveys carried out among more than 100 residents in Simon Community
hostels in 2015 found that 62% had been homeless for more than six
months. The proposed policy change will impact these people. Rather than
remove interim points, the DfC and the NIHE should revise and reform the
way in which points are awarded to ensure housing need is captured accurately, and address the shortage of homes which is at the root of the DfC
and NIHE’s attempts to mitigate the appearance of need.

Rathcoole residents presented 1,000 petitions from people in the community demanding that the NIHE and Minister
act immediately to open up and rent out approximately 100 publicly owned flats which have been available yet vacant
in their estate for around 4 years. Read more: https://www.pprproject.org/open-up-the-100-flats-now-rathcooleresidents-score-first-success-in-fighting-for-right-to-housing

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November 2017

Key Point #2

ABOLISHES INTIMIDATION POINTS
The DfC’s justification for the proposed abolition of intimidation points
(Proposal 7) rests on their assessment that the “number of households
awarded intimidation points is relatively small” despite the fact that data
shows that the numbers are “small” due to NIHE’s reticence to award interim points in cases where the threshold is met. The number of intimidated
households is significant and should not be dismissed through the removal
of points.


According to the Detail, there were 1,842 cases of people presenting as
homeless due to various forms of intimidation from 2012 to 2015: There
were 1,292 cases for paramilitary intimidation; 214 for anti-social behaviour;
48 for sexual orientation; and approximately 10 for disability. In 2014/15,
Base 2, a Northern Ireland Association for the Care and Resettlement of Offenders (NIACRO) funded project which “provides support and mediation
services to individuals and families at risk of violence or exclusion from their
community” sent 697 intimidation reports to NIHE but only 590 were received and intimidation points were awarded only in 383 cases.



PPR is concerned by the implication that those presenting as homeless due
to intimidation are “points chasers.” PPR’s experience of assisting people
made homeless through intimidation is that the process of assessment often
leads to individuals not receiving intimidation points despite reaching the required threshold of risk.

After more than three years after being
forced to flee their home in Tigers Bay following racist attacks, Mohammed Idris, Darelsalaam Yaquob and their three children are still
waiting for a home in North Belfast. They
were not awarded intimidation points. According to the NIHE, the family did not reach
the threshold for intimidation points because
“their home was not destroyed or seriously
damaged, nor was the family at serious and
imminent risk of being killed or seriously injured.” They are still living in temporary emergency accommodation in New Lodge.
Read more: http://www.itv.com/news/
utv/2017-06-21/family-still-in-temporaryhome-years-after-racist-attack/

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Key Point #3

PROMOTES PRIVATE
RENTED HOUSING
The proposals for instituting an “independent, tenure-neutral” housing advice service (Proposal 1) and allowing the NIHE to meet its statutory duty
to homeless applicants by further utilising the private rented sector
(Proposal 4) is problematic given the lack of security of tenure and rent
control together with poor property conditions and management standards
often encountered in this largely unregulated sector. Moreover, while advice can help people navigate a complex allocation system, it does not replace the building of houses.


A 2016 report by the Equality Commission NI entitled “Statement on Key Inequalities in Housing and Communities in Northern Ireland” found that households living in the private rented sector experience greater vulnerability, particularly in terms of substandard housing and the likelihood of increased poverty after the deduction of housing costs.



A 2016 publication by Housing Rights Service entitled “Review of the Private
Rented Sector” highlighted that there are various concerns surrounding the
sustainability of relying on the private renter sector “principally because of
the short (often 6 months) and insecure tenancies offered by private landlords.”

APPLIES A
PUNITIVE APPROACH
The DfC proposes making more people ineligible for social housing based
on “unacceptable behaviour at any time” before allocation of a social home
(Proposal 2), while proposals based on the perception of those in need of
social housing being “points-chasers” is evidenced by the recommended
removal of the award of intimidation points (Proposal 7) from the selection
scheme. This punitive approach also underlies the proposals abolishing interim accommodation points (Proposal 9), affecting policy succession
(Proposal 17), and the proposed set of vaguely worded circumstances
which a social landlord may rely on to withdraw an offer (Proposal 16).
PPR’s experience is that people often receive less points than they are entitled to, and should not therefore be penalised for claiming any entitlement
provided by law or policy.


In 2014, a group of 13 long-term homeless people took their cases to the
NIHE when launching the Homeless Action Charter. Each of them had spent
between 6 months and 30 months in cramped hostel accommodation where
they had fewer than 80 housing points each. Since the action, the NIHE
have reviewed their erroneous allocation of points. The “priority need” status
was immediately granted in two cases where it had previously been denied.
Moreover, additional housing points were awarded in 5 cases.



In 2016, PPR supported people in poor housing through the use of human
rights appeal letters to review their housing points. 699 extra housing points
were awarded to 32 families, 28 were given new offers of housing, 22 were
rehoused, and the long-standing maintenance issues of 17 families were finally addressed.
The group of 13 longterm homeless people
took their cases to the
upper levels of housing
provision when launching the Homeless Action
Charter on 16th September 2014.
Read more:
https://
www.pprproject.org/
rapid-improvements-forhostel-residentsasserting-their-right-to-a
-home

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Key Point #5

SUBVERTS THE PRINCIPLE
OF “OBJECTIVE NEED”
Proposals that allow landlords to multi-offer “difficult to let” properties to a
number of applicants regardless of their points allocation (Proposals 1214), encourages acceptance of properties that are likely to be in poorer
condition, and subverts the principle of “objective need.”


The NIHE was established in 1971 following the Cameron Report into the
civil disorder breaking out in the 1960s, which concluded that inadequate
housing provision and unfair allocation contributed to a “rising sense of continuing injustice and grievance” and pointed to a “misuse in certain areas of
discretionary power of allocation of houses in order to perpetuate Unionist
control of the local authority.” As such, the principle of awarding housing in
accordance with need lies at the very heart of the NIHE’s creation and existence, and should not be breached.



Despite this, people already suffer what the Equality Commission NI have
called “differing experiences of waiting lists for social housing, with a particular impact upon Catholic and other religions.” This is particularly the case in
locations where there is a shortfall in new social housing supply such as
North Belfast. The NIHE should be endeavouring to improve their record on
awarding housing according to need, not seeking to abandon the principle
altogether.

There are over 12,000 on the social
housing waiting list in Belfast. Over
6,000 are in ‘housing stress’. Yet, only
542 homes were completed in 2015.
The families, from all over the city, have
identified empty land at Dunnes/Hillview,
Mackies, Monagh Bypass, Sirocco
Quays, and Belfast Harbour which could
be used to build at least 1,000 homes.
Read more: https://www.pprproject.org/
equality-cant-wait-where-are-we-andwhere-to-next

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November 2017

Key Point #6

RESTRICTS
“REASONABLE” OFFERS
The policy states that if the two offers are refused, no further offers will
be made for one year after the date of the last refusal (Proposal 15). A
one year suspension from the waiting list would be applied if an applicant refuses two reasonable offers. Not only does this proposal fail to
consider refusals based on substandard housing, issues regarding what
the NIHE deems as “reasonable” have historically been a point of contention.
The negative impact of this change on applicants WILL NOT be balanced by the increase of choice they will have over the areas where
they would wish to live (Proposal 5).


PPR has assisted residents who are allocated housing deemed “reasonable”
by NIHE which are in very poor conditions, e.g., pigeon waste from communal landings, sewage systems which frequently overflowed through baths
and sinks; as well as campaigned for changes in multimillion pound plans
which ignored residents’ needs and the rehousing of the majority of families
into more suitable accommodation. Unless the current practice around what
constitutes “reasonable” or “unreasonable” changes then current issues surrounding poor quality housing will continue to arise.

In 2007, Kerry Haddock was living in the Seven Towers high rise development,
north Belfast, with her twin 5-year old daughters. She remembers the time as being very lonely. The housing conditions were poor and she experienced both
dampness and raw sewage regularly coming up her bath tub and sinks. When
Kerry reported the problems to the Northern Ireland Housing Executive – her
landlord - the problems never seemed to get sorted.
Read more: https://www.pprproject.org/ppr-group-member/kerry-haddock